VOO attaches great importance to your privacy and processes your personal data, hereinafter referred to as the “Data”, with the utmost care and transparency. VOO also makes it a point of honour to offer its clientele the best possible security. Below please find information relating to the Data processed by VOO as well as to your rights in respect of these Data.

Who is the party responsible for the processing of your Data (Data Controller) and how to contact them?

The Data Controller consists of two companies who are jointly responsible: Nethys SA (95 Rue Louvrex in 4000 Liège) and Brutélé SCRL (29 rue de Naples in 1050 Brussels), hereinafter jointly referred to as “VOO”. These two companies may be contacted using the form available from the voo.be website under the “Contact us” section, “Administrative” sub-section, to be returned for the attention of the DPO Office (Office of the Data Protection Officer) of Nethys at the address specified above, or for the attention of the DPO Office of Brutélé at the following address: BP 80.000 in Gosselies, or by email to privacy@nethys.be. To find out which party you should send the form to, please check your contract to see if was concluded with Brutélé or with Nethys. If you have any questions regarding the present privacy policy, please do not hesitate to consult the FAQ section on the VOO website.

The present privacy policy shall be amended from time to time. As such, VOO invites you to check the latest version on a regular basis. The latest version will be available on the VOO website at all times. Alternatively, a paper copy will be sent to you by request, sent to of one VOO’s DPOs. Each time substantial amendments are made, VOO will notify you beforehand at its own impetus through its website or through the usual channels of communication. The French version of the present policy shall take precedence.

Why are your Data processed?

First of all, VOO processes your Data in order to be able to perform the contract it has concluded with you or to put in place steps prior to entering into a contract, such as answering any questions you may have regarding our services. In doing so, VOO collects your identity details, your date of birth, your postal address(es), your e-mail address, your telephone and/or mobile phone number and your bank details. In order to enable VOO to raise its bills, VOO also processes data relating to the use you make of the various services offered. In order to enter into a contract with you, at a minimum VOO needs to have your identity details and contact details, as the address where the services are to be delivered. In doing so, you will be assigned an account number, an easyswitch identifier, a SIM card, modem and/or decoder number, as data which will also be registered by VOO. Similarly, if you do not yet have an account with VOO and you would like us to reply to questions you send in to us through our website, we will need your e-mail address or your telephone number to enable us to reply. Unless where you object thereto, we will store these data to send you information regarding our services. VOO also processes Data as part of the pursuit of its legitimate interests. This relates to improving our network, ensuring the network is working properly, gauging your satisfaction as a customer, answering your requests, improving our services, for commercial purposes, preventing and detecting any instances of fraud or maintaining security, for example. As such, VOO keeps a record of all contacts it has had with you through its various channels. Certain phone calls conducted with our services are also recorded to ensure the quality of the answers given to your questions. Your use and consumption habits of our services are collected to enable us to send you TV programme recommendations, to offer you discounts/benefits or present services and/or options which meet your expectations, as well as to help you choose which of our offers best complies with your actual needs. In addition, VOO may contact you again over a 2-year period after the expiry of your contract, based on your Data to inform you of its new commercial offers.

VOO also uses your Data on an aggregated and consequently anonymised basis to compile reports and trends regarding the use of its services for instance, such as the channels you watch or the volume of your internet consumption. The information which VOO derives from these analyses is used to appraise and improve our services.

VOO does not put in place any fully automated decisions in respect of yourself which could have legal consequences in regard to yourself or that could affect you in a significant manner, such as denying you access to certain products. However, VOO does raise profiles that are used by its agents to enter into contracts, or within the context of the performance of the contracts, notably to present you with offers or programmes that are likely to interest you. In doing so, evaluations of your socioeconomic situation are compiled, based on your socio-demographic situation and on statistics.

Moreover, a wide number of statutory and regulatory obligations are in place that require VOO to process and keep certain Data such as the bills (accounting and tax obligations), the traffic data relating to your communications or location data (obligations specific to telecom operators). In this respect, please rest assured that the latter Data are kept solely for the purposes set out by law, such as in order to comply with the requests from the judicial authorities or the intelligence services, to check the proper operation of the network or to deal with emergency calls, for instance. Also, in some cases, VOO will process Data based on your consent, for instance to disseminate the photo of the winner of a competition on our Facebook page or to establish your consumption profile to help you find the most appropriate offer for you. In that case, you will be duly and expressly informed, at the time when your consent is sought, of the reasons why VOO would like to use these Data. In addition, you should be aware that you are free to withdraw your consent at any time, without being required to state reasons. However, this will not affect the lawful nature of any processing that has taken place prior to the time you withdrew your consent.

Where are the Data sourced from?

By far the overriding bulk of the Data processed by VOO are collected either from yourself directly as it was you who provided them, or indirectly as they were gathered whilst you were using the services.
We are also provided with Data by third parties with your consent, in which case these are contact details (surname, first name, home address and telephone numbers) which enable VOO to contact you to present its services, in case you do not yet have an account with VOO.
In some cases, VOO will also collect Data that were made public on the internet. In that case, these are socio-demographic data such as your age, gender, town, data regarding your areas of interest or data relating to your surfing behaviour (number of clicks, duration of visits, pages visited on our voo.be website, on the VOO forums or on our Facebook page. These Data enable us to compile profiles in order to send out targeted advertising messages or to improve the appeal of our services, our websites and platforms. Unless your activities on the VOO forums or on our Facebook page are to do with the performance of your contract or where you provide us with your customer number, these data are collected on an aggregated and consequently anonymised basis without any links being established to yourself.

How long are your Data kept?

The retention period of your Data will vary depending on the reasons why they are processed. The bulk of the Data relating to your contract will be kept on record for the duration of the life of the contract and for a period of what in principle is ten years after the contractual relationship has ended. The data used for the purposes of predictive modelling are kept on record for a duration of 36 months. The traffic data are kept on record until the end of the time period during which you can protest the bill or until the end of the period during which proceedings may be brought to secure payment thereof; the location data are kept on record for the duration necessary to furnish the data traffic or the location services in question. The data relating to the access and to the connection of the terminal hardware to the network and the data intended to identify the user or the account holder are kept on record for twelve months.
The data of the surveillance cameras at some of our points of sale and the conversations with our agents are kept on record for no longer than a month.
The data relating to the prospects are kept on record for a year.
In some cases, where this is required by law or so as to safeguard VOO’s rights and interests, and particularly in the event of a dispute, Data may be kept on record for longer time spans insofar as this is necessary for the purposes outlined above.

To whom are my data disclosed?

VOO calls on the services of various service providers which, in some cases, may have access to some of your Data. To illustrate, VOO calls on self-employed installation engineers or technicians. Raising their bills and dispatching these bills is assigned to a third party service provider. The same applies to part of the management of the VOO website and the VOO forum. The call centres are managed by third party partners or other companies of the Nethys Group. VOO also calls on the services of independent resellers and discloses certain Data to third parties to recover unpaid debts or to analyse data and statistics. Data may also be disclosed to partners as part of marketing campaigns, for instance where prizes are handed out to competition winners. Data may also be transmitted to insurance companies in the event of loss claims. These various service providers have access only to the Data they need to perform the duties assigned to them by VOO. On no account are they able to use the Data which they have access to for any other purposes.
In addition, VOO is required by law to disclose Data to the emergency services or to certain authorities. If so requested by you, your data are also transmitted to the publishing houses of telephone directories.
In some cases, Data are transferred to service providers located outside of the European Economic Area for which the European Commission has returned an adequacy decision, acknowledging that these service providers offer an adequate level of protection for the Data transferred to them by a European entity. Your personal Data are then transferred on this basis.

What are your rights and how to exercise them?

In compliance with the applicable regulation, you have the following rights, which you may exercise free of charge and at any time, except in the event of abuse:

  1. - The right to request access to your Data (A)
  2. - The right to have your Data rectified (B)
  3. - The right to have your Data erased (C)
  4. - The right to object to your Data being processed (D)
  5. - The right to request for the processing of your Data to be restricted (E)
  6. - The right to Data portability (F)
  7. - The right to file a complaint with the Supervisory Authority (G)

A. Right of access

You have the right to request VOO to confirm whether or not the Data relating to you are processed and, if so, you may request access to the said Data. In that case, you will also be provided with the following information:

  • •the Data categories concerned and the purposes for which they are processed;
  • •the recipients or the recipient categories to whom the Data were or will be disclosed, in particular the recipients who are established in third countries;
  • •if possible, the planned retention period of the Data or failing this, the criteria adopted to determine this duration;
  • •the rights you have in respect of your Data, including the right to file a complaint with the Data Protection Authority;
  • •where the Data were not collected from yourself, all available information regarding their source;
  • •the existence of automated decision-making or the establishment of profiles and, as applicable, useful information regarding the logic behind any such decisions or profiles;

This right is easily exercised through the “Contact us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above. Please be aware that the traffic data relating to your communications may be disclosed only to the authorities specified in the law, which is why you are not allowed to have access to these data.

B. Right of rectification

You have the right to have Data relating to you, which are inaccurate or incomplete, rectified at any time. This right is easily exercised through the “Contact us” section, “Administrative” sub-section on VOO’s website, by calling 078/50.50.50 or by writing in to VOO’s Customer Service at 46 rue Jean Jaurès in 4430 Ans for Nethys account holders, or to 29 rue de Naples in 1050 Brussels for the Brutélé account holders.

C. Right to erasure

You have the right to request VOO to erase the Data relating to you in the following cases:

  1. a) the Data are no longer necessary for the purposes for which they were collected or where they are processed in another manner;
  2. b) you have withdrawn your consent on which the processing rests and no other legal basis for the processing exists;
  3. c) you have availed yourself of your right to object, as explained under paragraph D. below;
  4. d) your Data have been unlawfully processed;
  5. e) your Data are to be erased in order to comply with a statutory obligation;
  6. f) your Data were collected as part of an information society service offer, addressed to a child;

Where VOO needs your Data for the purposes for which they are processed, they shall therefore not be erased. Nor shall the Data be erased where the processing is necessary for VOO to comply with a statutory obligation, to perform the contract, to contact you or with a view to the establishment, the exercise or the defence of its rights before a court of law.

This right is easily exercised through the “Contact us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above.

If you wish to have your Data erased from the 1307 directory, please let VOO know. In that case however, your Data shall be left out of the paper directory only from the next edition forward. For the digital directory, your number will no longer be available when the 1307 directory next consults of our database.

If you wish to expedite matters, please also directly contact the 1307 directory, either by phone at 0800/ 98 033, or by e-mail, sent to annuaire@1307.be. Your number will be taken off the www.1307.be website within 48 hours.

D. Right to object to processing

You have the right to object, at any time, for reasons specific to your particular situation, to having your Data processed, including to having profiles compiled of yourself, performed by VOO in pursuit of its legitimate interests. In this case, VOO shall cease the processing unless this is necessary with a view to the establishment, the exercise or the defence of its rights before a court of law or where VOO is able to show that legitimate and compelling grounds exist that take precedence over your interests and your rights and freedoms.

For that matter, you have an absolute right to object to having your Data processed, including to having profiles compiled of yourself for commercial purposes. Please be aware that, in this case, it may be that you will be contacted again by VOO if, after having erased your Data at the end of the retention period or at your request, VOO is sent your data again from a third party with your consent.

This right is easily exercised through the “Contact us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above.

By way of general information, please be advised that you may object to the use of your landline or mobile telephone number by any businesses for publicity purposes, by signing up to the “ne m’appelez plus” (stop calling me) list at the https://www.dncm.be/fr/ website.

E. Right to restriction of processing

Where the processing is restricted, with the exception of the retention, the Data that are restricted may no longer be processed unless within the context of the restrictions established with your consent or with a view to the establishment, the exercise or the defence of VOOs rights before a court of law, or with a view to the protection of the rights of another person.

You have the right to request VOO to restrict its processing operations if any one of the following elements applies:

  1. a) you dispute the accuracy of the Data;
  2. b) the processing is unlawful but you do not wish to have your Data erased;
  3. c) VOO no longer needs the Data for processing purposes but your Data are still needed with a view to the establishment, the exercise or the defence of VOOs rights before a court of law;
  4. d) you have objected to having your Data processed and a check is made as to whether the legitimate interests pursued by VOO prevail over your interests.

This right is easily exercised through the “Contact us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above.

F. Right to Data portability

You have the right to be provided only with the Data relating to you which you supplied us with, with a view to the performance of the contract or with your consent and which are processed by way of automated procedures, and where these were either transmitted to you or to another Data Controller if this is technically possible.
If you wish to exercise this right, please inform us thereof at the time of your contract cancellation request.

G. Right to file a complaint with the Supervisory Authority

You may address all requests or complaints relating to the processing of your Data by VOO with the Belgian Supervisory Authority at:
Data Protection Authority
Rue de la Presse, 35, 1000 Brussels
Tel.: +32 (0)2 274 48 00
Fax : +32 (0)2 274 48 35
Email : contact(at)apd-gba.be
Or through its website at: https://www.autoriteprotectiondonnees.be/contact